Despite the U.S. government’s zero tolerance human trafficking policy, investigations have found that human trafficking by government contractors and subcontractors who operate overseas is still an issue. For example, in 2011, the Commission on Wartime Contracting – an independent, bipartisan legislative commission established to study wartime contracting in Iraq and Afghanistan – concluded that “[e]xisting prohibitions on such trafficking have failed to suppress it.” The commission also concluded that “evidence of the recurrent problem of trafficking in persons by labor brokers or subcontractors of contingency contractors.”

More than 70,000 third-country nationals work for contractors and subcontractors of the U.S. military in Iraq and Afghanistan.